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Stamp duty – Stamp duty land tax. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) allowed the appeal by Portland Gas Storage Ltd (Portland) against a decision of the First-tier Tribunal (Tax and Chancery Chamber)(FTT) in which the FTT had struck out Portland's appeal on the basis that it had no jurisdiction to hear the appeal where there had been no appealable decision by the Revenue and Customs Commissioners as required by para 35(1) of Sch 10 to the Finance Act 2003. The tribunal decided that certain letters sent by the Revenue to Portland had amounted to an enquiry into the return at issue and a closure notice with the result that Portland had had a right of appeal against the decision at issue.
Stamp duty – Stamp duty land tax. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) allowed the appeal by Portland Gas Storage Ltd (Portland) against a decision of the First-tier Tribunal (Tax and Chancery Chamber)(FTT) in which the FTT had struck out Portland's appeal on the basis that it had no jurisdiction to hear the appeal where there had been no appealable decision by the Revenue and Customs Commissioners as required by para 35(1) of Sch 10 to the Finance Act 2003. The tribunal decided that certain letters sent by the Revenue to Portland had amounted to an enquiry into the return at issue and a closure notice with the result that Portland had had a right of appeal against the decision at issue.
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